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Money Laundering

There's much jargon flying around in the world of counter-money laundering. It starts with the mistaken name of "anti-money laundering," via the equally erroneous "red flags" to the current vogue terms of "artificial intelligence" and "machine learning." As FinTech and RegTech have passed their media bubble phases, the next wave is so-called "AI AML."

Think about this: when you install any form of AI, you are outsourcing to the software providers the function that the law requires that your staff perform.

Before you even meet the representatives of the start-ups that want to either bolt onto or supplant your existing technology provider, there are several questions you must ask. Here they are.

According to a report in Business Insider, Mark Hayward, CEO of National Association of Estate Agents told the newspaper that “Fines are not publicly being made known but, anecdotally, we know they are significant,” The Money Laundering Regulations 2017 are at the heart of the HM Revenue and Customs action but The Criminal Finances Act also comes into play. The report refers to "fines" of "millions."

AUSTRAC statement

Are you a digital currency exchange provider?
16 January 2018 (updated 18 January)

India's Enforcement Directorate (ED) is involved in a rapidly increasing number of cases where money laundering is alleged and it is not afraid to go after high-profile, well connected, targets. But the latest case to gain publicity is even more sensitive than others. And the ED is finding itself the target of unwelcome attacks by some of India's most powerful people.

US President Trump has been looking for a win: for almost a year, the Senate has frustrated his legislative ambitions. His Bill to make fundamental changes to the USA's income and company tax structure was expected to be the next big failure. Instead, it has sailed through both Houses, but its final signing into law will be delayed due to "a procedural issue," although the result of that is a formality in favour of it being passed. Once in place, it will mean the biggest revision of the US Tax Code for more than 30 years. Some of the changes mean that MLROs etc. overseas will need to revise their policies.

The judgment in the AUSTRAC -v-Tabcorp civil case is a landmark: it's the first civil case that AUSTRAC has brought to a conclusion in court. But the judgment is only the latest step in a long running investigation and series of regulatory actions against the ASX-listed gambling giant.

A man who, through a corporate entity, operated off-street parking schemes on premises owned by a fund to raise money for former servicemen has been arrested after an investigation discovered that he, allegedly, failed to account to the fund for as much as USD11 million over a period of years.

The final (of three) part of World Money Laundering Report's analysis of the Manafort and Gates case and its implications for the financial services and other regulated industries.

Here, in this three part article, World Money Laundering Report examines the charges, the background and the impact on financial services and other regulated businesses.

Continuing our analysis of how Australia's Proceeds of Crime Act provides a mechanism for successful money laundering.

See Part I here

Late-stage money laundering is after the proceeds of criminal conduct have already been through a series of transactions to hide, move and even invest them. As the proceeds move further away from the original source, their origin is obscured but they are still not safe. Late-stage laundering usually involves using financial institutions or jurisdictions that are known to have good systems in place and therefore the next move is with the benefit of their reputation. Australia, on the other hand, provides - enshrined in its law - a safe haven that provides positive encouragement to launderers to place late-stage laundering there.

Part II here

It all began when the Philippines was found to have been the destination for the money stolen from the Central Bank of Bangladesh and, all over the world, fingers began to be pointed at the country's Swiss-cheese like counter-money laundering regime. What was especially bemusing to outsiders was that while the country was on one level constantly engaged in a battle with terrorists in the south, the laws to combat the funding of terrorism were in a similarly poor condition. Stung by criticism, the Philippines began to review its laws. One major area that had been entirely left out of account was casinos. In the past few months, that has dramatically changed.

Why, some might ask, is World Money Laundering Report drawing attention to violent crime statistics? "The figures released by the US government this week demonstrate that people engage in crime amongst those they have a major factor in common with, the "people like us" syndrome I discuss in "Understanding Suspicion in Financial Crime. Crime committed within defined groups, be they racial, social, religious or other groups, are at the heart of how and why so many offences are committed," Nigel Morris-Cotterill writes.

The final part of this article.

Continued from Part IV of this article

Continued from Part III of this article

Continued from Part II of this article

Part I is here

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